Supporting Statement for Paperwork Reduction Act Submissions|
Export
Import Bank of the United States
Application for Long Term Loan or Guarantee
OMB 3048-0013 EIB
95-10
General Instructions
A Supporting Statement, including the text of the notice to the public required by 5 CFR 1320.5(a)(i)(iv) and its actual or estimated date of publication in the Federal Register, must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below, and must contain information specified in Section A below. If an item is not applicable, provide a brief explanation. OMB reserves the right to require the submission of additional information with respect to any request for approval.
Specific Instructions
Justification
Explain the circumstances that make the collection of information
necessary. Identify any legal or administrative requirements that
necessitate the collection. Attach a copy of the appropriate
section of each statute and regulation mandating or authorizing the
collection of information.
The
Export Import Bank of the US (Ex-Im Bank) pursuant to the Export
Import Bank Act of 1945, as amended (12 USC 635, et seq),
facilitates the financing of exports of U.S. goods and services.
Ex-Im Bank is requesting an emergency approval for EIB 95-10
Application for Long Term Loan or Guarantee because the Export
Import Bank Reauthorization Act of 2012 has placed additional
reporting requirements on the Bank.
By neutralizing the effect of export credit
insurance and guarantees offered by foreign governments and by
absorbing credit risks that the private section will not accept,
Ex-Im Bank enables U.S. exporters to compete fairly in foreign
markets on the basis of price and product. This collection of
information is necessary, pursuant to 12 USC Sec. 635 (a) (1), to
determine eligibility of the applicant for Ex-Im Bank Assistance.
Indicate how, by whom and for what purpose the information is to be
used. Except for a new collection, indicate the actual use the
agency has made of the information received form the current
collection.
The collection will
provide information needed to determine compliance and
creditworthiness for transaction requests submitted to Ex-Im Bank
under its long-term guarantee and direct loan programs. The form is
currently used to make a credit decision on approximately 85 export
transactions per year in divisions dealing with aircraft, structured
finance, and trade finance.
Describe whether, and to what extent, the collection of information
involves the use of automated, electronic mechanical, or other
technological collection techniques or other forms of information
technology, e.g., permitting electronic submissions of responses,
and the basis for the decision for adopting this means of
collection. Also describe any consideration of using information
technology to reduce burden.
Ex-Im
Bank primarily receives this application (and supporting materials)
in hard copy (via mail or fax). However, Ex-Im Bank will also
accept PDF scans of original applications and all required
application attachments via email. Ex-Im Bank is considering a
business automation project that could, in the medium-term, allow
for electronic application submission.
Describe effort to identify duplication. Show specifically why any
similar information already available cannot be used or modified for
use for the purposes described in Item 2 above.
There
is no duplication of information submission because each application
corresponds to a unique loan or guarantee request. In circumstances
where some information may already be on file at Ex-Im Bank the
application includes language allowing the applicant to indicate so,
and thus not send in the information.
If the collection of information impacts small businesses or other
small entities describe any methods used to minimize burden.
The
applicants for long-term loans and guarantees are typically
financial institutions, foreign companies and governments that are
not
classified as small businesses.
Describe the consequence to Federal program or policy activities if
the collection is not conducted or is conducted less frequently, as
well as any technical or legal obstacles to reducing burden.
Absent the information required in
the application form, Ex-Im Bank would be unable to make the
necessary judgments to determine eligibility of the applicant to
obtain support. Without these judgments, Ex-Im Bank would not be
able to provide the guarantee or loan needed by its customers.
Explain any special circumstances that would cause an information
collection to be conducted in a manner”
*requiring
respondents to report information to the agency more often than
quarterly;
*requiring respondents to prepare a written response
to a collection of information in fewer than 30 days after receipt
of it;
*requiring respondents to submit more than an original
and two copies of any document;
*in connection with a
statistical survey, that is not designed to produce valid or
reliable results that can be generalized to the universe of
study;
*requiring the use of statistical data classification
that has not been reviewed and approved by OMB;
*that includes
a pledge of confidentiality that is not supported by authority
established in statute or regulation, that is not supported by
disclosure and data security policies that are consistent with the
pledge, or which unnecessarily impedes sharing of data with other
agencies for compatible confidential use; or
*requiring
respondents to submit proprietary trade secrets, or other
confidential information unless the agency can demonstrate that it
has instituted procedures to protect the information’s
confidentiality to the extent permitted by law.
This
collection is consistent with guidelines in 5 CFR 1320.6.
If applicable, provide a copy and identify the date and page number
of publication in the Federal Register of the agency’s notice
soliciting comments on the information collection prior to
submission to OMB. Summarize public comments received in response
to that notice and describe actions taken by the agency in response
to these comments.
The 60 Day
Federal Register Notice will be published January 16, 2013, Vol. #
77, Issue # 11.
Explain any decision to provide any payment or gift to respondents,
other than remuneration of contractors or grantees.
Not
applicable.
Describe any assurance of confidentiality provided to respondents
and the basis for the assurance in statute, regulation, or agency
policy.
Ex-Im Bank and its offices
and employees are subject to the Trade Secrets Act, 18 U.S.C. Sc
1905, which requires Ex-Im Bank to protect confidential business and
commercial information from disclosure, 12 CFR 404.1, which provides
that, except as required by law, Ex-Im Bank will not disclose
information provided in confidence without the submitter’s
consent.
Provide additional justification for any question of a sensitive
nature, such as sexual behavior and attitudes, religious beliefs,
and other matters that are commonly considered provides. This
justification should include the reasons why the agency considered
the questions necessary, the specific uses to be made of the
information, the explanation to be given to persons from whom the
information is requested, and any steps to be taken to obtain their
consent.
Not applicable.
Provide estimates of the hour burden of the collection of
information. The statement should include:
*the
number of respondents; 84
*the frequency of
response; On occasion
*annual hour burden;
1.5 hours
Provide an estimate for the total annual cost burden to respondents
or records keepers resulting from the collection of information.
(Do not include the cost of any hour burden shown in items
12).
Provide estimates of annualized costs to the Federal
government.
Reviewing Time 25
hours
Responses/year 84
Review time/year 2,100 hours
Avg
Wages/hr $30.25
Avg Wages/yr $63,525
Benefits &
Overhead 28% - $17,787
Total Government Cost $81,312
Explain the reasons for any program changes or adjusted reported in
items 12 or 13 of OMB from 83-1.
The
Export Import Bank Reauthorization Act of 2012 placed additional
reporting requirements on the Bank thus requiring the collection of
additional information from the Public and additional reviewing time
by Ex-Im Bank staff.
For collection of information whose results will be published,
outline plans for tabulation and publication. Address any complex
analytical techniques that will bee used. Provide the time schedule
for the entire project, including beginning and ending dates of the
collection of information, completion of report, publication dates,
and other actions.
Not applicable.
If seeking approval to not display the expiration date for OMB
approval of the information collection, explain the reasons that
display would be inappropriate.
Not
applicable.
Explain each exception to the certification statement identified in
Item 19 “Certification for Paperwork Reduction Act
Submissions,” of OMB Form 83-1.
Not
applicable.
Collection of Information Employing Statistical Methods
No
statistical methods were used.
| File Type | application/msword |
| File Title | Supporting Statement for Paperwork Reduction Act Submissions |
| Author | whitt |
| Last Modified By | whitt |
| File Modified | 2013-03-04 |
| File Created | 2013-03-04 |